143Although the Commission may take into consideration texts adopted within the framework of the OECD, it can in no way be bound by them, in particular as regards the application of the rules of the FEU Treaty and, specifically, the rules relating to State aid (see, to that effect, judgment of 12 May 2021, Luxembourg and Amazon v Commission, T‑816/17 and T‑318/18, under appeal, EU:T:2021:252, paragraph 154, and Opinion of Advocate General Kokott in État luxembourgeois (Information on a group of taxpayers), C‑437/19, EU:C:2021:450, point 67).
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